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Ano 101.22

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Old 17th May 2002, 23:27
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Ano 101.22

After a number of years away from instructing I am studying hard to get my rating back, hopefully a Grade 1 multi engine. While going through my multi engine notes I came across a copy of ANO 101.22 which obviously was a few years out of date. I have looked on the CASA web site and no CAO 101.22, I have talked to an FOI, “what’s CAO 101.22?”. Can anybody out there help me either to track it down or find out what replaced it. Its name was “Aircraft Certification Requirements – Aeroplanes in the Normal, Utility and Acrobatic Categories”

Thanks.
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Old 18th May 2002, 01:02
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In years gone by, Oz had its own certification requirements .. specified in the ANO (subsequently CAO) 101 series .. most all of which, post Yates report changes to the regs, have been consigned to the round filing cabinet. Most of the FOIs are too new to remember much about these old standards ....

Most of those orders called up an equivalent foreign standard and tacked a few extra things on for the benefit of the Australian industry .. some of these tack-on requirements were quite beneficial while others were only nuisance value - the old flight manual stowage provision usually was lumped in the latter category. Some of the older pilots would vaguely recall 101.5 for heavies of UK origin, 101.6 for heavies of US origin etc .... ANO 101.22 followed the US light aircraft standards CAR 3, and its successor, FAR 23.

There were some quite significant advantages in 101.22 for the local Industry, compared to the US standard in isolation, and, very regretably, these were thrown out with the baby and bathwater when the CAR changes came in to nominate strict compliance with the relevant foreign standard for subsequently certificated aircraft (the dreaded rubber stamp job ...).

It was sad that the Industry was driven by the desire of the large operators to gain a certification cost benefit for their particular Types of aircraft which they were happy to take as certificated OS. The downside was at a significant cost, in some cases, for local GA operators. The intent was to simplify things ... but it didn't quite work out that way ...

Let me give you a few for instances ....

(a) a very popular cabin class twin with a high wing has a significantly higher VFR MTOW in Australia due to a 101.22 OEI provision which was exploited sensibly by a significant operator back in the 60s/70s ... bit too far back to be precise in the memory .. long gone Forrester Stephens at Essendon if my recollection is correct. Couldn't do that with a new Type these days ...

(b) a well known and popular single engined turboprop, again with a high wing, first came in under 101.22 and had lots of seats ... the next model got caught by the new regs and would have been limited to the FAR 23 seating restrictions, which would make it pretty useless ... this was going to cause mucho dollar sales problems so the manufacturer had to recertify it in the UK so that it could be imported into Australia as a British aircraft rather than US .... by this expensive subterfuge, the aircraft came in with some more seats .. but has to be fitted with a bunch of things that are required under UK rules ... all quite silly and only because the regulators took away CASA's ability to be sensible and flexible in certification matters.

(c) in years gone by, modifications to aircraft would follow the foreign rules but these could be subject to variation in agreement with CASA and its antecedents ... not so now .... strict compliance is required ... has caused more than a few headaches ...

As to 101.22 replacements .. there were none, only a strict compliance with the relevant foreign NAA's requirements for the relevant class of aircraft.

I would have to check with Airworthiness as to the exact present state of play but I suspect that one could trot out 101.22 for modification work on older aircraft which were certificated in this country to that standard. Even then there was confusion ... The base order which worked well for years was ANO 101.22 Issue 2. Issue 3 was raised to permit a certain turboprop to get around some OEI certification difficulties and Issue 4 .. well, I never did quite find out why that was issued .. in practical terms we tended to stick with Issue 2 for pistons and Issue 3/4 for turpoprops.

So far as your rating study goes, 101.22 does not apply to any of the newer aircraft Types on the register but still probably does to certification aspects for the older twins. The relevant CAO 20.7 section applies to operational aspects, as you would be aware. The main consequence of all this dreadful mess is that people who don't have a detailed knowledge of the certification differences and history will eternally get into wonderful arguments as to this requirement and that .. when, oftentimes, the argument is irrelevant to the aircraft being discussed.

I have file copies of all the now cancelled 101.22 issues in case of any odd ball mod programs popping up in the future, so if you actually want to check any specifics, do send me a request by email .... and then I shall waste a day trying to find them in the dusty archives .....

ah .. the good old days ...

Last edited by john_tullamarine; 18th May 2002 at 01:13.
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Old 19th May 2002, 01:30
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Others, here and at the Dununder forum, have answered your question well. I doubt that 101.22 will come up on your renewal. Have a look at CAAP 5.23, that covers what you need to teach on twins. Good luck with your renewal. If you like, e-mail me, yours don't seem to work.
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